Welcome to part 2 of our series on subrecipient monitoring and management. Part 1 offers general advice on the subject, and this next post is intended to extend those tips and offer a few annotated sources for further reading. Thanks to Linda Butler (first section) and Linda Gilbertson (other sections), and our internal subject matter experts for their help.
Tips and Caveats
- Work closely with the program manager who knows the program/project best.
- Limit the amount of subrecipient grants management for consultants, and suggest that staff guide and complete this task.
- If a consultant is hired for this, serve as a reminder and editor with staff providing content.
- When a consultant takes on recipient management, staff tend to not take ownership of the project. Staff need to be aware that grants management includes program staff involved in the implementing, monitoring and evaluating of the grant.
Once a grant is awarded, all parties should meet as soon as possible to reestablish these expectations with concrete deadlines. Specific tasks should be assigned to actual people who will be working on the project. Meetings should be held at regular intervals, especially in the early phase of the project.
Complete documentation must be kept by the subrecipient and periodically reviewed by the recipient to determine how well the subrecipient is performing. This includes reviewing all expenditures as well as programmatic progress. Any problems that arise must be addressed immediately so remediation can be assessed to improve these outcomes. This requires a great deal of communication between the recipient and subrecipients, whether through weekly email check-ins or more formal meetings.
Role of the Pass-Through Entity
The recipient is totally responsible for the actions of any subrecipient. If the subrecipient is unsuccessful, the entire project will fail. It's not enough to just "keep tabs" on what the subrecipient is doing—it must be a formal process that everyone understands and agrees to at the very beginning. That way there won't be any surprises.
- Government of the District of Columbia. Subrecipient Monitoring Manual: District of Columbia Subrecipient Monitoring Manual. A good example of a thorough subrecipient monitoring manual.
- Harvard Financial Administration. Subrecipient Monitoring Policy: Harvard University Subrecipient Monitoring Policy. Offers a useful policy framework for other entities. A superb hub for other information branches: e.g., glossary, federal sources, and subject matter experts.
- Maryland Governor’s Grants Office. Subrecipient Monitoring and Management: Maryland Training Presentation. A robust resource on the what’s and why’s of the topic from one of the top grants offices in the nation.
Free Resource: 2 CFR 200 Training Videos
- VIDEOS: Uniform Guidance Simplified (Gil Tran, OMB)
- VIDEOS: Uniform Guidance Fundamentals (Victoria Collin, OMB)
- VIDEOS: Question & Answers about Indirect Costs (Panel)
- VIDEOS: Uniform Guidance Indirect Cost Training (Mak Karim, HHS)
- VIDEOS: COFAR Promising Practices (Panel)
See all posts.